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V1705-24 ·11 July 2024 ·consulta-vinculante Medium impact
Tax

Anglosaxon trust in Spain: rental attribution to legal owner; ISD on heritage distributions

A non-resident Spanish resident who established an anglosaxon trust asks how rental income from trust assets and distributions to heirs are taxed. The DGT states that rental income is attributed to the legal owner of the assets under article 11 of the LIRPF, without recognising the trust as a separate entity under Spanish law. Distributions to heirs upon the beneficiary's death constitute an ISD taxable event as a mortis causa acquisition.

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2024-07-11PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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